Frank H. and Marla C. Black - Page 26

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          college expenses.  During the years in issue, petitioners reduced           
          their home mortgage balance from $36,857 to zero and reduced                
          their home equity loan balance from $47,823 to $20,062.  In 1992,           
          they also spent a total of $32,299 for improvements to their                
          residence and landscaping.                                                  
               Mr. Black has a history of refusing to cooperate with                  
          respondent’s agents.  During the examination of his taxable years           
          1979 through 1981, Mr. Black refused to discuss the large                   
          deductions claimed for contributions to the Universal Life                  
          Church.  During Agent Helton’s investigation of taxable years               
          1987 through 1989, Mr. Black generally was unresponsive and                 
          evasive.  At trial, while cross-examining Agent Helton, Mr. Black           
          described his own behavior during that audit as “a little                   
               Finally, during the examination of his taxable years 1991              
          and 1992, Mr. Black refused to meet first with Agent McCarter and           
          then with both Agents McCarter and O’Dell.  Consequently, all of            
          Agent McCarter’s and Agent O’Dell’s contacts with Mr. Black were            
          made through his representatives.  Although the Agents attempted            
          to get Mr. Black to cooperate, he provided only limited records.            
          Mr. Black failed to provide records for the bank accounts that              
          were in his name.  Mr. Black refused respondent’s repeated                  
          requests to classify his checks as either business or personal              
          and to provide information concerning petitioners’ cash on hand.            

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